2. The Court has jurisdiction of this action pursuant
to 28 U.S.C. 1345, 42 U.S.C. 1973j(d), and 42 U.S.C. 1973aa-2.
In accordance with the provisions of 28 U.S.C. 2284, the
Section 203 claim must be heard and determined by a court of
three judges.

3. Defendant Orange County is a political subdivision
of the State of Florida and exists as a charter county,
organized pursuant to the laws of Florida. Pursuant to Fla.
Stat. Ann. 125.14 (West 2002) and the Orange County Charter,
Article VII, Section 706, the Board of County Commissioners
for Orange County is included in any suit against the county.

4. Defendant Bill Cowles is the Supervisor of Elections
of Orange County. The Supervisor of Elections has
responsibilities concerning the administration of voting and
elections in Orange County. Defendant Cowles is a resident of
Orange County, Florida, and is sued in his official capacity.

5. According to the 2000 Census, Orange County has a
total population of 896,344 persons, of whom 168,361 (18.8%)
are Hispanic persons; and a total voting-age population of
670,004 persons, of whom 116,884 (17.4%) are Hispanic persons.

6. Orange County is covered by Section 203 of the
Voting Rights Act of 1965, as amended, 42 U.S.C. 1973aa-1a
("Section 203") with respect to the Spanish language. 28
C.F.R. 55, Appendix. The Census Bureau has not released
figures from the 2000 Census for the Hispanic voting-age
citizens who are limited English proficient. According to the
1990 Census, 13,114 Hispanic voting-age citizens were limited
English proficient.

7. In conducting elections in Orange County, Defendants
have in some instances failed to furnish effectively, in the
Spanish language, the information and assistance necessary to
comply with Section 203 of the Voting Rights Act including,
but not limited to, failing to do the following:

b. translate into Spanish all election related
announcements, instructions, and notices at election sites; and

c. translate into Spanish all election-related
information, including but not limited to information about
candidate qualification procedures, letters to voters
regarding registration issues, information on Orange County's
elections internet site, and announcements for poll workers
posted on the Orange County Cable television channel.

8. Some voters at the November 2000 election requested
that poll watchers assist them in casting their ballots
because they were illiterate in English. Orange County did
not permit poll watchers to provide assistance to these voters
at the November 2000 election, and they did not receive
assistance from other persons.

FIRST CAUSE OF ACTION

9. Orange County is subject to the requirements
of Section 203, "any registration or voting notices, forms,
instructions, assistance, or other materials or information
relating to the electoral process, including ballots" that
Defendants provide in English must be furnished in the Spanish
language so that Spanish-speaking voters can be effectively
informed of and participate effectively in all voting-connected activities.
42 U.S.C. 1973aa-1a.

12. Unless enjoined by this Court, Defendants will
continue to violate Section 203 by failing to provide Orange
County's Hispanic citizens with limited-English proficiency
with the election information and assistance necessary for
their effective political participation.

SECOND CAUSE OF ACTION

13. Under Section 208 of the Voting Rights Act of 1965,
as amended, 42 U.S.C. 1973aa-6 ("Section 208"), Defendants
must permit voters to have the assistors of their choice: "Any
voter who requires assistance to vote by reason of blindness,
disability or inability to read or write may be given
assistance by a person of the voter's choice, other than the
voter's employer or agent of that employer or officer or agent
of the voter's union." 42 U.S.C. 1973aa-6.

14. Defendants' failure to allow voters the assistors
of their choice as described above in Paragraph 8, constitutes
a violation of Section 208 of the Voting Rights Act, 42 U.S.C. 1973aa-6.

15. Unless enjoined by this Court, Defendants will
continue to violate Section 208 by failing to provide Orange
County's voters with the opportunity to receive assistance
from persons of the voters' choice.

WHEREFORE, Plaintiff United States prays for an order:

Declaring that Defendants have failed to provide
Orange County's Hispanic citizens with limited-English proficiency
with election information and assistance in the Spanish language,
in violation of Section 203 of the Voting Rights Act, 42 U.S.C. 1973aa-1a;

Declaring that Defendants have not allowed certain Orange
County voters their assistors of choice, in violation of Section 208
of the Voting Rights Act, 42 U.S.C. 1973aa-6;

Enjoining Defendants, their agents and successors in
office, and all persons acting in concert with them, from failing
to provide Orange County's Hispanic citizens with limited-English
proficiency with election information in the Spanish language, in
violation of Section 203 of the Voting Rights Act, 42 U.S.C. 1973aa-1a;

Enjoining Defendants, their agents and successors in office,
and all persons acting in concert with them, from not allowing Orange
County's voters their assistors of choice, in violation of Section 208 of
the Voting Rights Act, 42 U.S.C. 1973aa-6;

Requiring Defendants to devise and implement a remedial plan
to ensure that Orange County's Hispanic citizens with limited-English proficiency
are able to be effectively informed of and participate effectively in all phases of the
electoral process, in compliance with Section 203 of the Voting Rights Act,
42 U.S.C. 1973aa-1a;

Requiring Defendants to devise and implement a remedial plan
to ensure that Orange County's voters are able to have their assistors
of choice when they cast their ballots, in compliance with Section 208
of the Voting Rights Act, 42 U.S.C. 1973aa-6; and

Requiring the Defendants to publicize effectively the remedial
plans and programs addressing the Section 203 and 208 violations enumerated herein to
ensure their widespread dissemination to Orange County's voters.

Plaintiff further prays that this Court order such
additional relief as the interests of justice may require,
together with the costs and disbursements in maintaining this action.